Khem R. Sharma, PhD
Chief, Size Standards Division
409 Third Street, SW, Mail Code 6530
Washington D.C. 20416
Subject: Proposed Rule Making – SBA RIN 3245-AG07
To whom it may concern:
The methodology utilized to set small business standards in various industries is an ongoing process, and we wish to applaud and support the SBA for taking this step to correct deficiencies and inconsistencies in certain established industries.
Given the scope and number of industries over which these size standards affect, it is all but inevitable that a ‘one size fits all’ approach will result in cases where a particular business will be classified as other than a “small business” in error. Such is the case, we believe, in our own industry and NAICS family.
As stated in the Federal Register notice of proposed rulemaking, the SBA recognizes that changes in industry structure in the market place have resulted in some existing size standards being no longer supportable by current data. The change in the size standard for our NAICS code is called for and we support the revised standard.
This proposed rule making is a giant step in the right direction and the recurring re-examination of what is the proper size standard and methodology will prevent changes in economic conditions, technological developments, and other outside influences to cause an unjustified shift in whether a particular firm or industry falls outside the standard, enters the standard size, remains within the standard size, or whether the standard needs to be adjusted.
We heartily support the proposed rule making and the proposed adjustments of size standards.
Sincerely,
R.J. Hallford
CFO
TerraSond Ltd
Comment on FR Doc # 2011-11707
This is comment on Proposed Rule
Small Business Size Standards; Professional, Scientific and Technical Services
View Comment
Related Comments
View AllPublic Submission Posted: 05/16/2011 ID: SBA-2011-0008-0362
Jun 15,2011 11:59 PM ET
Public Submission Posted: 05/16/2011 ID: SBA-2011-0008-0363
Jun 15,2011 11:59 PM ET
Public Submission Posted: 05/16/2011 ID: SBA-2011-0008-0368
Jun 15,2011 11:59 PM ET
Public Submission Posted: 05/16/2011 ID: SBA-2011-0008-0375
Jun 15,2011 11:59 PM ET
Public Submission Posted: 05/16/2011 ID: SBA-2011-0008-0385
Jun 15,2011 11:59 PM ET